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We begin by noting that petitioner bears the burden of
proving that respondent's determinations are incorrect. Welch v.
Helvering, 290 U.S. 111, 115 (1933).
The first issue for decision is whether Mr. Roberts is
petitioner's "dependent" as that term is defined in section 152.
A dependent is generally defined as an individual who
receives over half of his support from the taxpayer in the
calendar year in which the taxpayer's taxable year begins. Sec.
152(a). Individuals listed under this general definition
include, among others, the father of the taxpayer. Sec.
152(a)(4). In computing the amount which is contributed for the
support of an individual, there must be included any amount which
is contributed by such individual for his own support, including
income which is ordinarily excludable from gross income, such as
Social Security benefits. Sec. 1.152-1(a)(2)(ii), Income Tax
Regs.
Respondent argues that petitioner failed to meet the support
requirements of section 152(a). We agree. Petitioner has
offered no evidence that he paid for more than half of the costs
of supporting his father during 1992. Petitioner conceded at
trial that the entire amount of Mr. Roberts' Social Security
benefits and other income was applied against his nursing home
costs. Petitioner did not claim that his contributions exceeded
the amount contributed by Mr. Roberts for his own support.
Petitioner's testimony that he paid a portion of the costs of the
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